【Reference for G4】 Security trade control
Control Item:
The important checkpoints concerning security trade control in Japan and in other countries
are identified and well informed to everyone within the company. At the same time, it is
verified that the company complies with these requirements in the individual export, import,
release of software / technologies to foreign countries / individuals, brokering offshore trades
and brokering the release of software / technologies between foreign countries / individuals.
Points to confirm:
- How do you notify to everyone in your company about the matters to be observed on security
trade control in individual transactions of export, import, release of software / technologies
to foreign countries / individuals, brokering offshore trades and brokering the release of
software / technologies between foreign countries / individuals?
- What verification do you execute on security trade control including following points?
(1) Checkpoint carried out by persons in charge of sales before concluding contract;
(2) Production of documents on record of reviewed points; and
(3) Double-checking by personnel other than persons in charge of sales before shipment to
reconfirm compliance at the last minutes
Example of Standard Controls on Design & Operation required for SC Group Companies:
Internal regulations relating to security trade control have been established, and the following
are conducted:
1. As for exports, release of software / technologies to foreign countries/individuals,
brokering offshore trades and brokering the release of software / technologies between
foreign countries / individuals, persons in charge of sales confirm the following before
concluding contracts:
(1) whether goods and software / technologies are on the control list of the laws and
regulations or not;
(2) whether goods and software / technologies are suspected to be used for development,
production,use and storage of weapons of mass destruction, such as nuclear weapons,
chemical weapons, biological weapons and missiles for their delivery or not;
(3) whether the purposes of the transactions are or are suspected to be such special use
as for military use/ weapons and/or nuclear power. In case the final uses cannot be
confirmed, whether there are signs of such concerned use or not; and
(4) whether buyers, final end-users, and other related parties are considered to be armed
forces, nuclear energy companies, etc., or listed in the list published by the Japanese
government or other foreign governments or not.
2. As for exports, imports, release of software / technologies to foreign countries / individuals,
brokering offshore trades and brokering the release of software / technologies between
foreign countries / individuals, persons in charge of sales confirm the following before
concluding contracts:
(5) Whether places of origin of goods, countries where suppliers, etc., are located, countries
with effective control over suppliers, etc., transit / transshipment countries, countries
where buyers, etc., are located, countries with effective control over buyers, etc., and
countries where final end-user are located, are designated to special countries and/or
areas that require special attention in relation to the transactions.
3. When a transaction falls on any one of the above items (1) to (5), persons in charge of sales
apply and proceed with the transaction after producing checklists and other confirmation
records without fail in accordance with the internal regulations and obtaining designated
internal approval.
4. Persons in charge of logistics confirm the following before proceed shipping instructions:
(1) whether production of confirmation records relating to check items such as product
type, area, buyer and final end-user, etc., and end use, etc.;
(2) in case internal approval is necessary, whether such approval has been obtained or not,
and whether approval terms and conditions are fulfilled or not;
(3) whether the content of general license is available or not in case the company has such
license, and whether internal approval is obtained or not; and
(4) whether requested shipment falls within the range of the above-mentioned confirmation
records or the internal approval.
5. When the internally approved transaction requires an individual export license from the
competent authority based on the laws and regulations of security trade control, persons
in charge of sales submit necessary applications for license or report to such competent
governmental authority.
Quoted from: Internal Control Stadard Checklist No.79 BB-21
【Reference for G4】 Security trade control Control Item: The important checkpoints concerning security trade control in Japan and in other countries are identified and well informed to everyone within the company. At the same time, it is verified that the company complies with these requirements in the individual export, import, release of software / technologies to foreign countries / individuals, brokering offshore trades and brokering the release of software / technologies between foreign countries / individuals. Points to confirm: - How do you notify to everyone in your company about the matters to be observed on security trade control in individual transactions of export, import, release of software / technologies to foreign countries / individuals, brokering offshore trades and brokering the release of software / technologies between foreign countries / individuals? - What verification do you execute on security trade control including following points? (1) Checkpoint carried out by persons in charge of sales before concluding contract; (2) Production of documents on record of reviewed points; and (3) Double-checking by personnel other than persons in charge of sales before shipment to reconfirm compliance at the last minutes Example of Standard Controls on Design & Operation required for SC Group Companies: Internal regulations relating to security trade control have been established, and the following are conducted: 1. As for exports, release of software / technologies to foreign countries/individuals, brokering offshore trades and brokering the release of software / technologies between foreign countries / individuals, persons in charge of sales confirm the following before concluding contracts: (1) whether goods and software / technologies are on the control list of the laws and regulations or not; (2) whether goods and software / technologies are suspected to be used for development, production,use and storage of weapons of mass destruction, such as nuclear weapons, chemical weapons, biological weapons and missiles for their delivery or not; (3) whether the purposes of the transactions are or are suspected to be such special use as for military use/ weapons and/or nuclear power. In case the final uses cannot be confirmed, whether there are signs of such concerned use or not; and (4) whether buyers, final end-users, and other related parties are considered to be armed forces, nuclear energy companies, etc., or listed in the list published by the Japanese government or other foreign governments or not. 2. As for exports, imports, release of software / technologies to foreign countries / individuals, brokering offshore trades and brokering the release of software / technologies between foreign countries / individuals, persons in charge of sales confirm the following before concluding contracts: (5) Whether places of origin of goods, countries where suppliers, etc., are located, countries with effective control over suppliers, etc., transit / transshipment countries, countries where buyers, etc., are located, countries with effective control over buyers, etc., and countries where final end-user are located, are designated to special countries and/or areas that require special attention in relation to the transactions. 3. When a transaction falls on any one of the above items (1) to (5), persons in charge of sales apply and proceed with the transaction after producing checklists and other confirmation records without fail in accordance with the internal regulations and obtaining designated internal approval. 4. Persons in charge of logistics confirm the following before proceed shipping instructions: (1) whether production of confirmation records relating to check items such as product type, area, buyer and final end-user, etc., and end use, etc.; (2) in case internal approval is necessary, whether such approval has been obtained or not, and whether approval terms and conditions are fulfilled or not; (3) whether the content of general license is available or not in case the company has such license, and whether internal approval is obtained or not; and (4) whether requested shipment falls within the range of the above-mentioned confirmation records or the internal approval. 5. When the internally approved transaction requires an individual export license from the competent authority based on the laws and regulations of security trade control, persons in charge of sales submit necessary applications for license or report to such competent governmental authority. Quoted from: Internal Control Stadard Checklist No.79 BB-21
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